Legal Opinion

Weis v. Commissioner

United States Tax Court

Decided March 21, 1990No. Docket Nos. 26336-88, 27525-88, 27526-88, 27527-88, 30233-88, 30235-88PublishedCited by 62 opinions

F, a limited partnership, purchased a farm in 1981 for a contract price in the amount of $ 870,000. Pursuant to the contract, F was required to pay $ 205,000 to the seller upon closing. The remaining balance of the contract price, $ 665,000, was to be paid by F in five minimum annual installments of $ 11,500 plus a balloon payment due 6 years after the closing date of the outstanding balance remaining due under the contract. The contract did not provide for interest.

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F, a limited partnership, purchased a farm in 1981 for a contract price in the amount of $ 870,000. Pursuant to the contract, F was required to pay $ 205,000 to the seller upon closing. The remaining balance of the contract price, $ 665,000, was to be paid by F in five minimum annual installments of $ 11,500 plus a balloon payment due 6 years after the closing date of the outstanding balance remaining due under the contract. The contract did not provide for interest. Held: The amount of interest imputed under the contract, and the rate at which it is to be deducted, is governed by sec. 483.…

1Opinion of the Court

OPINION

FAY, Judge:

Respondent determined deficiencies in and additions to petitioners’ Federal income tax as follows: Docket No. 26336-88, Thomas J. and Gloria J. Weis:

Additions to tax

Year Deficiency Sec. 6653(a)(1) 2 Sec. 6653(a)(2) Sec. 6659 Sec. 6661

1982 $6,855 $343 * $558 $1,249

1983 5,836 292 * 457 1,078

Docket No. 27525-88, Pat Savaiano:

Addition to tax

Year Deficiency Sec. 6659

1983 $4,527 $387.60

Docket No. 27526-88, Pat Savaiano and Carol Savaiano:

Additions to tax

Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659

1982 $1,324 $66.20 * $203.40

Docket No. 27527-88, Pat Savaiano and Ann M.…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  3. Marcello v. CommissionerUnited States Tax Court · 1964
  4. Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
  5. Conlorez Corp. v. CommissionerUnited States Tax Court · 1968

3 more not listed; retrieve them via the Exa API.

3Cited by62 opinions

  1. Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
  2. Condor Int'l v. CommissionerUnited States Tax Court · 1992
  3. Sacks v. CommissionerUnited States Tax Court · 1994
  4. Berger v. CommissionerUnited States Tax Court · 1996
  5. Estate of Ratliff v. CommissionerUnited States Tax Court · 1993

57 more not listed; retrieve them via the Exa API.

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